The accused was arrested for an armed carjacking after police intercepted the stolen vehicle.
During the arrest, an officer grounded the accused, causing a minor cut to his chin, to secure a replica handgun tucked in his waistband.
The accused subsequently gave a videotaped statement to police.
On a confessional voir dire, the defence argued the statement was involuntary due to oppressive police conduct, specifically the use of force during the arrest.
The court found the officer's use of force was reasonable and necessary given the dynamic and high-risk situation of an armed suspect.
The court concluded the accused's will was not overborne, and the statement was voluntary and admissible.
